FEAD contribution to the Call for Evidence on harmonisation of rules for calculating and verifying recycled content in plastic packaging

FEAD, the European Waste Management Association representing the private waste and resource management industry across Europe, welcomes the upcoming secondary legislation under Article 7 PPWR on the calculation and verification of recycled content.

During the development of the SUPD methodology and for chemical recycling, FEAD supported a polymer-only allocation approach, rather than the fuel-use-excluded approach ultimately retained. Nevertheless, the SUPD methodology is now the result of several years of technical discussions across the value chain. Reopening this debate under the PPWR would create unnecessary uncertainty and, most importantly, risk delaying the application of the recycled content targets.

FEAD therefore considers that ensuring the timely application of these targets should take priority over revisiting the agreed methodology and supports replicating the SUPD calculation and verification approach, with only the adjustments strictly necessary to reflect the broader scope and specific requirements of Article 7 PPWR.

Replicate the SUPD approach when possible and adapt when necessary

The Implementing Act should build on the methodology already established under the Implementing Decision of the SUPD for the calculation, verification and reporting of recycled plastic content in single-use plastic beverage bottles. This methodology provides a robust and harmonised framework for determining recycled content. Reopening the underlying mass balance methodology would delay the implementation of the recycled content targets and undermine investment in European recycling capacity, despite the absence of any significant technological or market developments justifying such a revision.

The PPWR Implementing Act should therefore replicate, wherever possible, the calculation, mass balance allocation, traceability and verification rules established under the SUPD. Only those elements that are strictly necessary to reflect the broader scope of the PPWR should be adapted, such as the calculation of recycled content for individual plastic parts or the integration of the methodology into the PPWR conformity assessment and technical documentation.

In particular, the Implementing Act should preserve the core principles of the SUPD methodology, including calculation points, the use of measured recycled content where available, mass balance accounting where necessary, the three-month accounting period, traceability throughout the value chain, harmonised declarations and targeted third-party verification.

The Implementing Act should also provide clear and harmonised definitions of key concepts, including ‘plastic part’, ‘manufacturing plant’, ‘packaging type’ and ‘packaging format’, as these concepts determine how compliance is assessed throughout the value chain.

Sanctuarise the approach in the PPWR Guidance and Q&A

The Commission Notice and the PPWR FAQ, published in 2026, already provide useful clarifications regarding the implementation of Article 7. These interpretations should be fully reflected in the Implementing Act in order to ensure legal certainty and avoid diverging national interpretations.

In particular, the Implementing Act should confirm that:

• Each discrete plastic part representing at least 5% of the total weight of the packaging shall comply separately with the recycled content obligation.
• Recycled content is calculated at the manufacturing plant level for each plastic part subject to Article 7.
• The final manufacturer compiles the information received from upstream suppliers as part of the technical documentation required under Annex VII.
• Exemptions provided for under Article 7(5) are self-awarded but supported by appropriate documented evidence, including on the absence of authorised recycling technologies for this application, in line with the Commission Notice.

Traceability along the value chain

Standardised traceability practices, such as those set out in EN 15343, ISO 22096, or equivalent standards, must be implemented throughout the supply chain, down to the filling of packaging, to ensure a chain of custody model is in place so the origin of recycled content can be reliably tracked at every steps.

Packaging producers, including importers, must demonstrate the complete chain of custody, tracking the material from the original waste stream to the final packaging, and must document it as part of the technical documentation referred to in Annex VII of PPWR and accompanying the packaging.

Interlink with other PPWR secondary legislation

In conclusion, the calculation and verification methodology cannot be considered in isolation from the other secondary legislation under Article 7 PPWR, in particular the sustainability criteria and the rules ensuring equivalent conditions for recycled plastics from third countries. These instruments should be developed in a coherent and complementary manner, without creating overlapping requirements or reopening the agreed calculation methodology. Their effectiveness will also depend on harmonised implementation and enforcement across Member States, supported by common verification requirements and consistent interpretation by competent authorities.

FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be